Corporate Compliance

Developing an audit plan

Compliance Monitor, April 28, 2006

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Q:Can you offer any tips for creating an audit plan?

A:Developing an effective audit program can be complex, so it helps to be very familiar with top risk areas and challenges.

The first step is to prioritize your risk areas to develop your audit plan, and analyze the following factors for each risk:

  • Level of work done by external auditors
  • Financial exposure
  • Legal exposure
  • Potential for adverse publicity
  • Level of work done by corporate internal audit services
  • Quality of internal control environment
  • Time and findings since last review

    In its Compliance Program Guidance for Hospitals, the Office of Inspector General (OIG) outlines its expectations for an effective healthcare compliance program. It recommends that providers perform audits of coded data at least annually and suggests that monitoring of coded data should be performed on a regular basis.

    In all 300 coding compliance settlements involving healthcare providers, the OIG has required the provider to perform annual coding audits, which serve two very important purposes.

    First, they ensure that any errors or patterns of error are identified. Second, they serve as ongoing oversight. The government hopes that audits will affect coders and HIM departments as peer-review affects physicians: They are more cautious with patient treatment when they know that their care is likely to be peer-reviewed.

    This tip is an excerpt from the new HCPro publication The Compliance Officer's Handbook. For more information, visit our Web page at http://www.hcmarketplace.com/prod-3922.html.



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